Chicago, Burlington & Quincy Railway Co. v. United States

Background

The federal government sued a railroad company that ran interstate trains, seeking penalties for using cars that lacked required safety appliances under Congress’s Safety Appliance Acts. Two district actions were consolidated; at trial the court directed guilty verdicts and entered judgments of $300 and $100 for violations involving automatic couplers and braking appliances. The Circuit Court of Appeals affirmed after noting the carrier had conceded the cars were defective but argued lack of knowledge and reasonable inspections.

Reasoning

The key question was whether the statute imposed an absolute duty on interstate carriers to have required couplers and brakes, or whether a carrier could avoid penalties by showing it had no knowledge of defects or had exercised ordinary care and inspections. The Court reviewed prior decisions, especially a previous case about drawbars, and found the statutory language plainly displaced common-law negligence and created an absolute statutory duty. Because the penalty at issue is civil, the Court held carriers are liable for violations even when they lacked actual knowledge or had used ordinary care.

Real world impact

As a practical matter, rail companies moving interstate traffic must ensure cars have the mandated automatic couplers and braking appliances at all times or face civil penalties. The opinion explains that courts across the federal system have followed this interpretation, that trial courts may direct verdicts when the evidence is undisputed, and that only Congress can change this statutory rule—not the courts. It also emphasized that employees injured by equipment used contrary to the statute are not deemed to have assumed the risk.